There’s some good information in the FAA’s new five-year Unmanned Aircraft Systems (UAS) forecast, but there are reasons to doubt the accuracy of the agency’s projections in two areas that have captured attention: the claims that there will be roughly threefold growth in the numbers of commercial drones and UAS-certified pilots. Here's the good, the bad, and the ugly in the report.

The Good

There is some good analysis in this report. For example, it seems the FAA finally gets that drones have a wide variety of price points and the bulk of commercial activity has been driven by low-cost consumer-grade aircraft:

“Currently, the consumer grade dominates the non-model sector with a market share approaching 95 percent. However, as the sector matures and the industry begins to consolidate, the share of consumer grade non-model aircraft is likely to decline but will still be dominant. By 2023, FAA projects this sub-sector will have around 85 per-cent share of the overall non-model sUAS sector.”

This insight is mostly consistent with independent surveys and reports like this one, which finds more than 91% said they bought drones costing over $2,000 for professional purposes—either governmental, academic, or business.

The other good thing in this report is the FAA’s admission that the historical commercial drone registrations outpaced their own predictions by 80%. Previously, they predicted a healthy growth rate of more than 40%—but they underestimated it.

“Last year, we forecasted that the non-model sector would have around 229,400 sUAS in 2019, a growth rate exceeding 44 percent from the year before (2018). Actual data far exceeds that trend with over 277,000 aircraft already registered by the end of 2018. Our forecast of non-model sUAS last year thus fell short by almost 80 percent for 2018 (or 277,000 actual aircraft vs 158,900 that we projected last year).”

The Bad

A closer look at the report reveals a few oversights and curious assumptions for their forecasts. Some of the key metrics and growth trajectories came from a survey the FAA conducted in June-July of 2018 about commercial activities performed in 2017 under Part 107. The survey sent to 89,000 individuals was intended to get a snapshot of non-model/commercial mission characteristics, including locations, aircraft types used, and altitudes flown. But the response rate to the survey—which was complex and time consuming—was low (approximately 8 percent).

Still, the report projects the U.S. commercial drone fleet (small non-model UAS) to nearly triple from 277,386 in 2018 to 835,211 in 2023, an average annual growth rate of almost 25 percent. However, the main oversight is that most people don’t deregister their aircraft. They may if they register a new one, but if they stop using one they are not going into the Registry to delete it. This keeps the current number inflated.

Another noticeable problem is the survey results are inconsistent with internal FAA data. And to be fair, the FAA admits there are big variations between the survey results and their aircraft registry. For instance, almost a third of survey respondents use one small drone; their aircraft registry (i.e., the Registry) indicates 55 percent use one small drone. The survey indicates that, for those operating multiple small drones, 54 percent operate 2-9, but the registry claims just on third fly multiple drones.

Another issue is the survey found the largest commercial use for drones was in R&D and in training/education missions (21%). But year over year, other industry benchmark surveys find the number one use for commercial drones is aerial photography and video. This disconnect is no surprise given how the FAA worded their survey questions. In this instance, the question asked for the number of missions performed on average per aircraft in each of activity they listed, not about its major intended use. Given most businesses were new to drones in 2017, it makes sense that the FAA found a lot of aircraft flew training missions back then—not actual industrial missions such as mapping and inspections as happens today.

The Ugly

Perhaps the biggest problem with the FAA report is in the Remote Pilot Forecast section. It predicts the number of UAS-certified pilots is “set to experience tremendous growth following the growth trends of the non-model sUAS sector.” It predicts commercial drone activities may require almost 350,000 remote pilots in five years—a three-fold increase. Many in the press have run with this assumption and taken it to mean that the commercial drone industry is set to triple in the next five years. But a closer look calls this into question and makes that forecast specious.

To start, the FAA does not maintain a database showing the number of remote pilot certificate (RPC) holders who are current. They only report gross new RPC holders. As reported here, 126,299 individuals have been issued a remote pilot certificate as of March 15, 2019. But as of the same day, only 7,306 individuals have taken the remote pilot certification recurrent knowledge test, which is required every two years. Given remote pilot certification started in August 2016, that means only 20% of the original pilots have renewed their license to operate commercially. To be fair, that figure may be higher but not by much since Part 61 pilots with an existing RPC and have met their flight review requirements are considered RPC current.

If the number of certified remote pilots is the benchmark for commercial drone industry growth (because, almost uniformly around the world, regulations demand each drone operation have one pilot), it seems crucial the FAA keep and report a database on current RPC holders in the U.S. That information would enable all to predict with greater certainty the growth of the commercial drone industry.